10. The Plaintiff hereby elects an accounting of the Defendants' profits, rather than the Plaintiff's damages, and now seeks to have the quantum of said profits determined by way of a Reference

As a result of the foregoing, THE PLAINTIFF REQUESTS THAT:

11. The Referee schedule a reference to quantify the profits realized by the
Defendants as a result of their infringement, pursuant to Rule 153 et seq. of the Federal Courts Rules, in accordance with the issues identified in the Plaintiffs Statement of Issues;

12. A timetable be set for the conduct of the Reference, including discovery of the
Defendants, pursuant to Rules 3, 153(2), 156 and 157 by the Referee;

What's next?

As Plaintiff's counsel is refusing to Delay the Order until the Appeal is decided, the defendants will have to file a motion for Stay of the Order.